SUMMARY: Water
is more precious than copper, zinc or gold � or company profits.
The use of cyanide in mining poses an unreasonable risk to the health
of people, wildlife and fish in Wisconsin. The claimed benefits of mining
do not outweigh the potential for long-term or permanent environmental
damage, especially in the pristine areas of Northern Wisconsin where most
potential mine sites are located.

There are alternatives to cyanide. The EPA lists several alternatives
to cyanide. In 1999, 16 of 18 leading U.S. zinc mines did
not use cyanide. 11 of 15 leading U.S. copper mines
did not use cyanide.

Cyanide is an extremely toxic and volatile chemical. A teaspoon
of 2% cyanide solution can kill humans and much smaller amounts are deadly
to fish and wildlife. Under certain conditions, cyanide can break down
to form many compounds with chemicals and metals. Some of these cyanide-related
compounds remain toxic and are not regulated or monitored.

The mining industry is not subject to hazardous waste laws that apply
to other industries. Unlike industrial users of cyanide that are required
to destroy cyanide waste, mining companies are allowed to landfill cyanide
waste and to rely on natural degradation to reduce concentrations. Natural
degradation relies on sunlight and warm temperatures � unreliable conditions
in northern Wisconsin for much of the year.

Cyanide accidents happen regardless of process. Flotation and
heap-leach ore processing each use many of the same technologies. More
than half of 62 recent accidents in Montana � before voters there restricted
the use of cyanide in mining � were caused by liner leaks, waste spills,
human error or storm events � problems not specific to heap leaching.

Flotation ore processing has caused environmental degradation.
In 1994, the EPA reported that a mine using the froth flotation process,
the Colorado Black Cloud Mine consistently exceeded limits for cyanide
with discharges that were shown to be toxic to aquatic life.

The mining industry deserves to be treated differently. Metallic
mining accounts for more than half of the nation's toxic releases, a recent
EPA report says. The Crandon mine alone would use 10 times the cyanide
of any other Wisconsin industry. Mining is treated differently in many
current environmental laws, such as less-stringent groundwater standards.

The issue is fish and aquatic life. Coffee, lima beans, almonds
and road salt may contain cyanide, but it has different properties and
is less toxic than the cyanide used in mining. Humans metabolize low levels
of cyanide � but fish and aquatic life cannot.

The ban on cyanide has statewide support. The Conservation Congress
voted by a 10-to-1 margin to support the ban. More than 20 local governments
have passed resolutions in support.

Water is more precious than copper, zinc or gold �
or mining company profits. The use of cyanide in mining poses an unreasonable
risk to the health of people, wildlife and fish in Wisconsin. The claimed
benefits of mining do not outweigh the potential for long-term or permanent
environmental damage, especially in the pristine areas of Northern Wisconsin
where most potential mine sites are located.

1. There are
alternatives to cyanide. The EPA lists several alternatives to cyanide.
In 1999, 16 of 18 leading U.S. zinc mines and 11 of 15 leading U.S. copper
mines did not use cyanide.

EPA lists several alternative chemicals used in zinc and copper mining
that serve the same function as sodium cyanide. For zinc mining, they
are sulfur dioxide, zinc sulfate, sodium hydrogen sulfide, and for copper
mining: zinc hydrosulfate, dichromate, zinc sulfate, and sodium bisulfate.
Sodium cyanide is the reagent of choice because it is cheap and effective,
despite its toxicity.

2. Cyanide is
an extremely toxic and volatile chemical. Cyanide measured in the
small parts per billion range are toxic or cause injury to fish and other
aquatic life. Should a tanker spill or a waste dump leak or overflow and
fail to contain cyanide-laced mining wastes, the result could be catastrophic.
Under certain conditions, cyanide can break down to form compounds with
chemicals and metals. But many of these cyanide-related compounds remain
toxic and are not regulated or monitored. A teaspoon of 2% cyanide solution
can kill humans.

Estimates of cyanide concentrations in waste tailings at Nicolet Minerals
Co. (NMC) mine (approx. 14 parts per million) would be much higher than
standards for both aquatic life and for drinking water - 20 and 200 parts
per billion respectively. If NMC�s wastes were spilled into Swamp Creek,
the results could be catastrophic for everyone downstream, including the
Wolf River. Even if wastes don�t spill, cyanide-laced wastewater can harm
birds and other wildlife. For example, 2700 birds died in 1995 after drinking
water contaminated with cyanide from the tailings pond at the Northparkes
copper and gold mine in New South Wales, Australia. 1000 migratory birds
were killed when they drank cyanide-laced water at an Echo Bay mine in
Nevada in 1989 and 1990.

3. The mining
industry is not subject to hazardous waste laws that apply to other industries.
Unlike industrial users of cyanide that are required to destroy cyanide
waste, mining companies are allowed to landfill cyanide waste and to rely
on natural degradation to reduce concentrations. Natural degradation relies
on sunlight and warm temperatures � unreliable conditions in northern
Wisconsin for much of the year.

Do other companies in Wisconsin use cyanide? Some do, but this
is not the whole story. NMC states that cyanide is being shipped
to approximately 50 "users" in the state. Only three companies
used cyanide in high enough amounts to have to report their wastes to
the federal Toxic Release Inventory (TRI, 1999 data). Only three Wisconsin
companies had wastes of more than 500 pounds or more for 1999. Of the
three, two reported approximately 2500 pounds or less. The largest user
in the state reported approx. 48,000 pounds of cyanide wastes.

By comparison, NMC would � at the highest estimated rate of use � dispose
of nearly 500,000 pounds per year, or about 10 times the amount of the
state�s current largest cyanide user. Moreover, other companies are not
allowed to simply landfill cyanide wastes such as in NMC�s plans for the
proposed Crandon mine. Other industry using cyanide either ship the wastes
to waste handlers to be destroyed, or destroy cyanide at their operations
due to strict discharge and land disposal restrictions.

Wisconsin mining companies benefit from the loophole allowing them
to landfill its cyanide wastes, unlike other industry. Ironically,
NMC demands to be treated like other state industry using cyanide despite
laws giving mining special treatment. Other state companies using cyanide
do not landfill cyanide wastes as NMC proposes to do in its tailings dump
and in the abandoned mine. This is because mining is exempt from hazardous
waste laws, even if its wastes contain cyanide. Other state industry is
simply not allowed to do the same. Mining also is allowed to use wetlands
for waste sites and to pollute groundwater in a much greater amounts than
any other industry in the state � more examples of special treatment for
mining wastes.

4. Cyanide accidents
happen regardless of process. Flotation and heap-leach ore processing each
use many of the same technologies. More than half of 62 recent accidents in
Montana � before voters there restricted the use of cyanide in mining � were
caused by liner leaks, waste spills, human error or storm events � problems
common to all forms of mining.

NMC is trying to isolate itself from the mining industry�s horrible track record with cyanide use. Hardrock mining, whether for gold or for zinc, utilizes many of the same technologies. A review of more than sixty cyanide releases in just one western state, Montana, from 1982 to 1998 reveals that more than half were caused by liner system leaks, waste spills or overflows, human error or accidents, or storm events. These problems are not specific to heap-leach mining only; they consist of technology or situations found in common with Nicolet Minerals Crandon proposal.

Waste dump and liner failures have taken place at mines around the world in recent years include a 1998 pipeline rupture that spilled more than 14,000 lbs. of sulfuric acid at an Arizona mine run by one of NMC�s owners, BHP. BHP operates the Ok Tedi mine in Papua New Guinea where since 1984 it has discharged 80,000 tons of untreated mine wastes directly into the Ok Tedi River daily. BHP now admits it wishes it was not involved with the Ok Tedi disaster. Another parent of NMC, Billiton, reported several spills at other mines it owns last year. Others include:

1998, six to seven tons of cyanide-laced tailings spilled from the Homestake
Mine into Whitewood Creek in the Black Hills of South Dakota, resulting in
a substantial fish kill.

In 1995, more than 860 million gallons of cyanide-laden tailings were released
into a major river in Guyana when a dam collapsed at Cambior mining company�s
Omai gold mine.

In 1989 and 1990, a series of eight cyanide leaks occurred at Echo Bay Company's
McCoy/Cove gold mine in Nevada, releasing a total of almost 900 pounds of
cyanide into the environment.April 1998 a dam at the Los Frailes zinc mine
in southern Spain ruptured and released an estimated 1.3 billion gallons of
acid, metal-laden tailings into a major river and over adjacent farmlands.

Transportation of Cyanide Could Lead to Accidents. For instance, on
April 5, 2001, a truck carrying cyanide went off the road and crashed in South
Dakota. Authorities said they were lucky the truck crashed into a snowbank,
which cushioned the blow and prevented release of the cyanide. A May 1998 truck
accident delivering cyanide to a mine in Kyrgyzstan overturned into the Barskoon
River. Four people, as well as livestock and fish, were reportedly killed as
a result of the spill. NMC is not responsible for accidents should cyanide
be spilled while being trucked to the mine site.

5. Flotation ore processing
has caused environmental degradation. Copper and zinc mines using flotation
are not immune to accidents and problems with processing chemicals and wastes
(see #4 above). The mining industry has also claimed that no mine using flotation
has caused environmental problems. This assertion is false.

One example is Asarco's Black Cloud mine in Colorado. It was a zinc/lead mine that closed in 1999 and used cyanide froth flotation for processing ores just as NMC proposes for Crandon. In 1994, the EPA reported that the Black Cloud mine, "�consistently exceeded discharge limitations for total suspended solids, cyanide, zinc, and manganese," and that the discharge was shown to be toxic to aquatic life. Permit records show that Black Cloud continued to discharge cyanide above permitted levels. Black Cloud mine failed seven more quarterly monitoring tests for cyanide in the mid-1990�s.

In 1999, only two of eighteen leading zinc mines nationwide reported cyanide in mine wastes. Of those two, the Black Cloud, mine reported permit violations for cyanide. Of the two, Cominco�s Red Dog zinc mine in Alaska began using cyanide that year. In May and June of 2000, the Red Dog mine exceeded discharge limits for cyanide.

NMC says that froth flotation has been safely used for 70 years. There is
simply no evidence to support this claim. There is no 70-year history of
safe cyanide use in U.S. flotation mining. Until 1976, there were no uniform
federal regulations for the industry�s wastes and discharges, nor were mining
wastes routinely monitored for safety.

6. The mining industry
deserves to be treated differently. Metallic mining accounts for more than
half of the nation's toxic releases, a recent EPA report says. And mining is
treated differently in many current environmental laws, such as less-stringent
groundwater standards.

It is common for legislatures to target regulations and to restrict
or prohibit certain activities related to a broader problem. Courts have repeatedly
upheld such regulations. NMC has threatened to sue the state if it enacts a
ban on the use of cyanide in mining, but such an equal protection challenge
has little chance of success.

Mining is treated differently already.
It is regulated under its own chapter of the statutes (Ch. 293) that give it
special treatment. For example, mining in Wisconsin is exempted from Ch. NR
103 wetland restrictions; mining also is exempt from the state�s groundwater
laws. Instead, less stringent groundwater laws were crafted only for the mining
industry.

Miningisdifferent
than other industries. It takes place in the natural environment. For
instance, the Crandon mine is in the middle of wetlands and is surrounded by
lakes and streams that flow into one of the state�s most treasured resources,
the Wolf River � which flows into Lakes Poygan, Butte des Morts and Winnebago.

Mining deserves to be targeted. An April 2001 report by the federal
EPA said metallic mining is responsible for more than half the releases of toxic
substances ("materials that cause death, disease, or birth defects in organisms
that ingest or absorb them") into the environment. NMC�s proposal would use
up to ten times as much cyanide as any other single company in WI. Mining
wastes in Wisconsin are exempt from federal hazardous waste laws � even if the
wastes contain cyanide.

At least one mining company is drilling for gold in Wisconsin. Royal Standard Minerals is interested in using cyanide for ore processing should it obtain permits to mine the Bend deposit in Taylor County in the Chequamegon/Nicolet National Forest in Wisconsin.

7. The issue is fish
and aquatic life. Coffee, lima beans, almonds and road salt may contain
cyanide, but it has different properties and is less toxic than the cyanide
used in mining. Humans metabolize low levels of cyanide � but fish, the aquatic
life they depend on, and other wildlife cannot.

Mining companies say that cyanide degrades naturally in harmless substances. NMC expects natural degradation of sodium cyanide in its mine wastes to reduce concentrations. This process relies on sunlight and warm temperatures � conditions rarely seen in northern Wisconsin for much of the year. Even if sodium cyanide breaks down, it forms other metal-cyanide compounds that are just as dangerous and that are not monitored for and are not regulated. Mining companies say cyanide is in coffee and other foods, implying that this somehow makes mine wastes safe.

Fish don�t drink coffee. People can easily metabolize the form of cyanide
found in some foods. However, much smaller amounts are toxic to wildlife and
especially to fish and other aquatic life. The cyanide compounds found naturally
in some foods (lima beans, coffee, sorghum, others) are not the more toxic sodium
cyanide. The minute amounts of cyanide in coffee cannot be compared to hundreds
of thousands of pounds of sodium cyanide used at mine sites.

NMC states that iron cyanide for road salt is "stable and non-toxic"
and that the wastes to be dumped into the abandoned mine will contain this form
of cyanide. Iron cyanide � a different form of cyanide than used in mining �
is sometimes used as an anti-caking agent in road salt. Due to the negative
affects of its usage, such as damage to bridges and toxicity to aquatic life
from salts and cyanide, most states are experimenting with alternatives to road
salt.Last year, the Canadian equivalent of our EPA, Environment Canada,
determined that road salts containing iron cyanide were in fact toxic and
harming fish and other aquatic life.

Studies show that some of the sodium cyanide used at the Crandon proposal will be changed to iron cyanide that will be disposed of in the mine. First, modeling shows that wastes in the mine will eventually mix with groundwater and can ultimately be discharged to surface waters. Second, iron cyanide is not the benign substance NMC wants it to be. Iron cyanide can break down in sunlight or in acid conditions and change into the most toxic form, free cyanide. Third, iron cyanide is not the only from of cyanide that will be present in mine wastes dumped underground. Other more soluble and unregulated forms will be present as well.

NMC would landfill cyanide-laced wastes at the mine site. The concentration
of cyanide in the wastes to be dumped above ground in the tailings dump will
be high enough to cause environmental damage if the waste dump leaks; is overtopped
or overflows; is breached; or if birds or other wildlife drink from the pond
that would exist on top. The cyanide concentrations in the waste dump will be
more than one thousand times as high as what is projected to be dumped into
the abandoned mine.

8. The ban on cyanide
has strong statewide support. The Conservation Congress voted by a 10-to-1
margin to support the ban. More than 45 Local governments, Counties, Tribes,
environmental and conservation organizations have passed resolutions in support
of SB 160/AB 95. They include the counties of Rusk (site of the Ladysmith mine)
and Langlade (downstream from the Crandon site), the cities of New London, Appleton,
and Milwaukee, and numerous townships along the Wolf River and Lake Winnebago.